Facts

Which states outside the EU are reportable under the KStTG?

Only third states with which a qualifying agreement exists, meaning an exchange agreement whose equivalence the European Commission has determined; the BMF and the BZSt have not published an official list of such states so far.

Source: KStTG section 1(13) and (21) (gesetze-im-internet.de); BZSt DAC8 procedure page, which names no list of states. As of 21.10.2026.

A reportable person within the meaning of this Act is anyone resident for tax purposes in a member state of the European Union or in a third state with which a qualifying agreement exists, and who is not an excluded person.

Context

What exists is the path towards it: 56 jurisdictions have signed the OECD's CARF agreement (OECD list, status 03.03.2026), Germany on 26.11.2024; 46 committed to first exchanges by 2027, 27 by 2028 and 4 by 2029 (Global Forum, status 14.09.2026). A signature is not yet a qualifying agreement. The self-certification has to be collected from every user regardless.

The legal position in detail, with every list

Related facts

Checked against the source named above on 21/10/2026. We publish only statements traceable to a statute, an official journal, a BMF or BZSt publication, or to one of our own disclosed datasets. This page states the legal position and is not legal or tax advice.

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